John M. Morris is the general manager of The Edge Radio and an instructor of Radio and TV at the University of Southern Indiana. Campus View appears regularly at radioworld.com.
Get ready noncommercial educational radio stations, we will soon have to move our public files online with the FCC. The good news is that for most of us, we have until March 1, 2018, to get this done. The FCC, as expected, approved the new rules for radio stations (as well as cable operators, satellite TV providers and satellite radio licensees).
So what does this mean?
We’ll start with the good news:
- Once you have your files online, you will no longer have to maintain your local public file. This should mean that we won’t have to worry about someone coming to our stations to see the public file. This should remove some liability that many of us face due to our school schedules, but, broadcast attorney David Oxenford says that stations must still have a staffed main studio that is accessible to the public during regular office hours
- We will only have to upload new files not already on file with the FCC
- If you want to put your files online earlier than 2018, the the FCC says go ahead. There is a catch though, once you start, you must stay with the online option
- According to Rec Networks, LPFM stations are exempt from ruling this ruling concerning placing public files online
That was the good news.
Now for the other side:
- We will be required to upload our donor list (for donors that give to sponsor a specific program). The FCC has stated that they will entertain waivers for this requirement under certain circumstances
- Whatever we are required to put in our public file now will also be required when we go online
- A link to the public and political files will be required on our website’s home page
- Once this is fully implemented, the general public will be able to easily access the online public files. This means that we will all need to be very diligent about getting things filed on time
- This will also mean some more work. Right now, we can just print out what goes in the file. Instead, it will be online. Each station will need to make sure someone is trained to do this properly and in a timely fashion
- You will need to retain local backup copies of your political file in case the online file becomes inaccessible
- You will need to provide the FCC with an email contact address. It will be important to ensure that this address is monitored on a continual basis
There is a gray area in the new rules according to Oxenford, and that is the question of any requirements for Class D stations. Some of these stations are exempt from some of the public file rules, but they are not directly mentioned in the online filing rules.
We all knew this was coming, and now we know the date. I hope this helps. And as always, it’s always good to have an attorney guide you through anything you do with the FCC.